Privacy Policy

Last Updated: May 25, 2018

RECENT UPDATES TO THIS NOTICE:

  • THIS PRIVACY NOTICE HAS BEEN UPDATED TO REFLECT REQUIREMENTS OF THE GENERAL DATA PROTECTION REGULATION (GDPR).
  • A DESCRIPTION HAS BEEN CREATED TO CLARIFY HOW CLEARSTAR HANDLES PERSONAL INFORMATION OF SCREENING SERVICES AND CUSTOMERS.

This Notice explains what personal data is collected by ClearStar, Inc. (“ClearStar”) and how and why it is used. The details of ClearStar’s processing of personal information will vary depending upon why we are interacting with you. ClearStar also applies this Privacy Notice in the offline context, such as when an individual places an order or requests information by mail or telephone. This Notice only applies to ClearStar and its affiliated entities.

This Notice is layered. Please click on the link that has to do with your interest.

For a list of terminology used in this Notice, please see: TERMINOLOGY USED IN THIS PRIVACY NOTICE

General Privacy Information Pertaining to ClearStar’s Data Collection

This section pertains to all of ClearStar’s data processing.

Privacy Vision
ClearStar is committed to the responsible use of information and protecting individual privacy rights. ClearStar provides services to mitigate risk, facilitate more informed decisions, and make the world safer, and we strive to do this in ways that protect the privacy of individuals (also referred to as “consumers”) who interact with us. ClearStar aspires to protect consumer privacy through the design of its processes, by credentialing, monitoring, and/or auditing its clients as appropriate, and through other information security safeguards. ClearStar also strives to promote transparency through appropriate opportunities for choice, access, and correction with respect to personal information about the individual.

Privacy Advocate
The ClearStar Privacy Advocate is Kerstin Bagus, Director of Global Initiatives.
To request information or receive help with data protection and privacy issues, contact ClearStar’s Privacy Advocate at:

Privacy@ClearStar.net
United States: (770) 416-1900 x872
United Kingdom (Toll Free): +44 (800) 3688795
Headquarters’ Address: 5955 Shiloh Rd. El, Suite 104, Alpharetta, GA 30005

Alternative Use of Information Collected
If ClearStar is going to use your personal information in a manner different from what was stated at the time of collection, ClearStar will notify you via email, if an email address has been provided and is available. You will have a choice if you wish to allow ClearStar to use your information in such a different manner.

Data Retention
ClearStar retains data for as long as needed to address our business requirements and legal obligations. If you have questions about the specific data retention of information collected on you, contact our Privacy Advocate at Privacy@ClearStar.net.

Security
ClearStar takes steps to protect against the loss, misuse, or unauthorized alteration of personal information collected through our websites and business. ClearStar recognizes the importance of security for all personal information we collect. Once ClearStar receives personal information, ClearStar takes steps to protect its security on its systems. In the event ClearStar requests or transmits sensitive information, such as credit card information or Social Security Numbers through this Website, ClearStar uses industry standard, secure socket layer (SSL) encryption.

ClearStar limits access to personal information to those employees or service providers who need access in order to carry out their job responsibilities.

When ClearStar disposes of personal information, ClearStar uses procedures to dispose of personal information by means such as shredding documents and erasure of electronic media that information cannot be practicably read or reconstructed. In some cases, such as with some backups, information will be rendered inaccessible rather than destroyed.

Children and ClearStar’s Website and Services
ClearStar’s Websites and services are not intended for children and ClearStar does not knowingly collect any information about or from children aged 13 or under. ClearStar is committed to complying with applicable laws and requirements, such as the United States’ Children’s Online Privacy Protection Act (“COPPA”).

ClearStar Website & Marketing Privacy Information

This section describes how ClearStar handles information when individuals interact with our website, www.clearstar.net or interact with us as a prospective customer. Our website is hosted in the United States.

ClearStar’s Websites may contain links to unrelated third-party websites. ClearStar assumes no responsibility for the content or the privacy policies and practices on those websites. ClearStar encourages all users to read the privacy statements of those sites; their privacy practices may differ from those of ClearStar.

The use of ClearStar Websites indicates your agreement to ClearStar’s Privacy Notice.

How ClearStar Collects and Uses Information on its Websites
You can visit our Website, www.clearstar.net, without revealing information about yourself. ClearStar Web servers automatically collect the domain names, not the e-mail addresses, of visitors. This information is used to measure the number of visits, average time spent on the site, pages viewed and similar information. ClearStar uses this information to measure the use of its Website and to develop ideas to improve the content of its Website.

Our Website collects personal information from you if you choose to provide this information to us. The information collected may include name, company name, e-mail address, and telephone number. If you email or call us, we may also request your mailing address. If you respond to a survey, we will collect the responses along with any contact information provided. ClearStar may request this type of information if you contact us by mail or telephone.

When interacting with our Website, we will collect your IP address via a cookie. We use this information to monitor the effectiveness of our Website and to provide you with relevant ads when you interact with Facebook or LinkedIn.

ClearStar collects marketing information on individuals to fulfill queries about our services. We also collect contact information when you sign up for updates with us, such as company announcements. Our marketing communications contain an unsubscribe option at the bottom of each email.

Cookies
“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Our Website uses first and third-party cookies, however personally identifiable information is not collected using cookies with the exception of IP addresses. The IP address is anonymized prior to storage in a cookie. We use cookies to understand how our visitors use our Website and for fraud prevention. Cookies expire in 24 hours.

While most browsers are set to accept cookies by default, you can set yours to refuse cookies or to alert you before accepting them. Your browser manufacturer has information on changing the default setting for your specific browser. However, be aware that if you do not accept cookies from our Websites, you may not be able to use some of the features our Website.

Non-personally-identifiable information
ClearStar Websites also collect non-personally-identifiable information. For example, as you browse this Website, ClearStar may collect information about your visit but not about you personally. For example, ClearStar uses web server logs to monitor statistics such as: the number of people that visit its Website, which page(s) are visited on its Website, from which domain visitors come (e.g., google.com, msn.com, etc.), and which browsers people use to visit this Website (e.g., Google Chrome, Microsoft Internet Explorer, etc.). This Website may use an outsourcing program to assist ClearStar in analyzing this data to better tailor ClearStar Website.

Information Use and Consumer Choice
The information collected by our Websites is used only for responding to your inquiries and otherwise corresponding with you and for the administration, review and/or improving the content of ClearStar Websites. ClearStar does not share, sell, rent or trade PII with third-parties for their promotional/marketing purposes.

ClearStar may contact you in response to your comments or inquiries, as part of the maintenance of your account with us (if you have one), or in order to complete a transaction that you requested.

ClearStar may also contact you to inform you of other products or services ClearStar believes may be of interest to you, but ClearStar always offers you an opportunity to opt not to receive such communications.

If you decide that you do not want to receive further e-mails regarding your inquiry from ClearStar, you can e-mail ClearStar’s Privacy Office at Privacy@ClearStar.net with a request that ClearStar does not continue to e-mail you. ClearStar does not use outside data sources to enrich marketing data obtained online.

ClearStar Website users have the option to request that ClearStar not use information previously provided, correct information previously provided, or remove information previously provided to ClearStar. Individuals who would like to correct or suppress information provided to ClearStar should contact the ClearStar Consumer Advocacy Group at Service@ClearStar.net. The inquiries should include the individual’s name, address, and other relevant contact information (phone number, email address), as well as the nature of the request. Except as required by law, ClearStar is free to deny such requests. If ClearStar decides to grant such a request, it will use all reasonable efforts to honor such requests as soon as practicable.

Onward Transfer
Information from an individual’s visit to our website is provided to Google Analytics to assist us in improving the effectiveness of our website.

If you wish to opt-out of the availability of your activity on Google Analytics, you may do so by installing the Google Analytics opt-out browser add-on. This add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

If you contacted us with a sales inquiry, that information may be entered into a Customer Relationship Management program so that we may manage your contacts. We use two programs: NetSuite (www.netsuite.com), with data stored in the United States, and Freshdesk (www.freshdesk.com), with data stored in Ireland. We have appropriate service agreements in place with both organizations.
ClearStar may disclose personal information when required by law or in the good faith belief that such action is necessary in order to conform with the law or to comply with a legal process.

Transfer to Other Countries
ClearStar’s Website is hosted in the United States. By interacting with our Website, you are agreeing to the transfer of your information to the United States.

ClearStar’s Customer Relationship Management program data is stored in the United States or in Ireland.

Access and Correction
As an information service company, ClearStar understands the importance of comprehensive data. ClearStar will provide you with access to personal information you provide to us for as long as ClearStar maintains that information in a readily accessible format. Similarly, ClearStar permits and encourages you to correct inaccuracies in the information submitted to ClearStar through this Website.

If you wish to access information held on you by ClearStar or request the correction of information you feel is incorrect, please use the mechanisms provided by the Website, or send an e-mail to Service@ClearStar.net. The access and correction provisions of this online privacy only apply to personal information collected from you through ClearStar Websites. If you wish to have information about how to access and/or request the correction of personal information ClearStar on you maintained by ClearStar as we provide screening services, see the section on ClearStar Services, Obtaining Information about ClearStar’s Consumer Privacy Practices.

ClearStar Customer Management Privacy Information

ClearStar is a provider of web technology services and screening solutions, which includes background screening and occupational health screening. We process customer information in order to maintain the appropriate contact information to manage an account, including invoicing.

Information Use and Consumer Choice
The information collected for customer management is used only for responding to your inquiries, corresponding with you about our services, and for maintaining your account. ClearStar does not share, sell, rent or trade PII with third-parties for their promotional/marketing purposes.

If you decide that you do not want to be listed as a representative for your company in our account management systems, or if the information is incorrect, you can e-mail ClearStar’s Privacy Office at Service@ClearStar.net with your request.

Onward Transfer
ClearStar uses two Customer Relationship Management programs; NetSuite (www.netsuite.com), with data stored in the United States, and Freshdesk (www.freshdesk.com), with data stored in Ireland. We have appropriate service agreements in place with both organizations.

ClearStar may disclose personal information when required by law or in the good faith belief that such action is necessary in order to conform with the law or to comply with a legal process.

Transfer to Other Countries
ClearStar’s Customer Relationship Management program data is stored in the United States or in Ireland.

ClearStar Services Privacy Information

ClearStar is a provider of web technology services and screening solutions, which includes background screening and occupational health screening. When we process personal information for service provision, ClearStar is a processor or sub-processor, acting under the direction of a controller. The entity requesting the service is the entity who will determine the lawful basis for processing and the purpose of the processing.

Data from screening services is stored in the United States or Ireland.

How ClearStar Collects and Uses Information When Providing Services
ClearStar’s customer must collect certain information from you to process the requested screen. The personal information collected may include names, date of birth, address and address history, identification numbers, driver’s license number, contact information, education history, and employment history. If you are signing a digital notice or consent form, we may collect your IP address to assist in confirming your identity on this form. Please note, this list is not all inclusive; the specific information collected will vary depending upon the type of services requested and what is required by the source of the information. For example, a background search may require an identification number, such as a U.S. Social Security number, while a different search may require a copy of a country ID, or a residence address. ClearStar balances the need of the collection of personal information with need for information required to produce an accurate result. We strive to minimize collection of personal information.

If you are interacting with us on one of our ordering portal websites, we will collect your IP address during the session. We use first party cookies. Cookies allow ClearStar to store your User ID during your visit to keep track of your sessions with us, or if you are a customer, to keep track of reports you have ordered or any updates to those reports. Cookies also help ClearStar detect potential fraud or misuse of its system.

While most browsers are set to accept cookies by default, you can set yours to refuse cookies or to alert you before accepting them. Your browser manufacturer has information on changing the default setting for your specific browser. However, be aware that if you do not accept cookies from our Websites, you will not be able to use some of the features of the Websites, such as those for ordering reports.

ClearStar may contact you in response to your comments or inquiries, as part of the maintenance of your account with us (if you have one). ClearStar, or our third parties, may contact you in order to complete a transaction that you requested or approved. For example, we may contact you to schedule appointments or to obtain information to complete the requested screen.

Information Use and Consumer Choice
The information collected by our portal websites is used only for processing transactions requested by our customer or data subjects, maintaining an account (if you have one), and for the administration, review and/or improving the content of ClearStar websites. ClearStar does not share, sell, rent or trade personal information with third-parties for their promotional/marketing purposes. ClearStar does not re-use or re-purpose information collected during the screening process.

If you wish to stop the processing of data you have previously consented to, you may do so by contacting ClearStar directly. In such case, ClearStar will make every attempt to stop the processing as quickly as possible. To stop any processing, contact us with a request that ClearStar discontinue any processing about you. We will inform the requesting customer that you have indicated the processing of this screen is to be stopped.

The contact to stop processing of your information is our Privacy Department:

Privacy@ClearStar.net
United States: (770) 416-1900 x872
United Kingdom (Toll Free): +44 (800) 3688795

Onward Transfer
ClearStar may disclose information provided to us to third-parties so that we may complete a requested transaction. For example, if a background screen is requested, we may send that request to a third-party to obtain the information for us. Our third-party service providers can be located around the world. ClearStar enters into service agreements with these third-parties and requires that the companies acting on ClearStar’s behalf abide by the ClearStar privacy notice and institute safeguards to protect the confidentiality of your information. Note that if we work with a service provider in another country, your personal information may be processed in countries that may have data protection laws that are different than the laws in your home country. Please see the section titled INTERNATIONAL COLLECTION & CROSS-BORDER TRANSFER OF PERSONAL INFORMATION for more information on our international data transfers.

ClearStar may disclose personal information when required by law or in the good faith belief that such action is necessary in order to conform with the law or to comply with a legal process.

Information Use for FCRA Purposes

A number of services offered by ClearStar are Consumer Reports (“Consumer Reports”), as the term is defined under the U.S. federal Fair Credit Reporting Act (“FCRA”), and when providing Consumer Reports to its Clients in the United States, ClearStar acts as a Consumer Reporting Agency (“CRA”) as the term is defined under the FCRA, operating in accordance with the requirements of the FCRA. The FCRA establishes the following principles for all CRAs:

Privacy: Information about you may only be furnished to third-parties that have a permissible purpose to request such information. In general, these deal with credit, employment, insurance, rental or banking transactions initiated by you, or where the object is to make a firm offer to you. CRAs must credential their clients to make certain that they have a permissible purpose to receive the requested information.

Access: Consumers in the United States may receive a copy of information the CRA maintains about them. Such reports can be obtained nationally free of charge once per 12 months, twice in some states, or for a reasonable fee for additional disclosures. Please contact ClearStar at Service@ClearStar.net or call toll free 1-877-275-7099 if you need more information.

Individuals located outside of the United States who wish to have a copy of information we maintain about them may contact our Privacy Advocate at

Privacy@ClearStar.net
United States: (770) 416-1900 x872
United Kingdom (Toll Free): +44 (800) 3688795

Accuracy: CRAs must follow reasonable procedures to assure accuracy of the information they maintain and/or furnish. When you obtain a copy of your information, you have a right to dispute and have the information reinvestigated and corrected in the CRAs database.

Fairness: Information is obtained from various sources including public records sources. However, certain information over a specified time period may not be reported.

Accountability: The Federal Trade Commission is in charge with overseeing the operations of CRAs that provide consumer reports for employment and residential screening purposes and enforcing the FCRA requirements.

When ClearStar provides Consumer Reports on U.S. residents, it is subject to the FCRA and operates within FCRA framework. If you would like to obtain a report about the information ClearStar maintains about you, please call toll free 1-877-275-7099 or email Service@ClearStar.net.

For credit reports from the credit bureaus, please visit: https://www.annualcreditreport.com/cra/index.jsp.

Privacy Notice: Preparation and Processing of Investigative Consumer Reports


This notice is provided to California residents. Under California law, an “investigative consumer report” is a consumer report containing information on a consumer’s character, general reputation, personal characteristics, or mode of living. ClearStar may provide investigative consumer reports about individuals and in such case, it provides them to business for employment screening, resident screening, and similar purposes.

Personal Information Disclosure: United States or Overseas


In connection with its preparation and processing of consumer reports and investigative consumer reports, ClearStar may transfer personal information about you to ClearStar authorized service providers and affiliates outside the United States and its territories. In such case, the transfer will be conducted in accordance with all applicable laws and regulations.

Obtaining Information about ClearStar’s Consumer Privacy Practices

To obtain additional information about the privacy practices and policies of ClearStar in connection with its preparation and processing of consumer reports, please contact our Privacy Advocate at

Privacy@ClearStar.net
United States: (770) 416-1900 x872
United Kingdom (Toll Free): +44 (800) 3688795

For additional information about privacy or consumer reporting, visit the following websites:

California Office of Privacy Protection: www.privacy.ca.gov

Consumer Data Industry Association: www.cdiaonline.org

Consumer Financial Protection Bureau: www.consumerfinance.gov
Equifax: www.equifax.com

Experian: www.experian.com/consumer/credit_education.html

Federal Trade Commission: www.ftc.gov

TransUnion: www.transunion.com

International Collection & Cross-Border Transfer of Personal Information

ClearStar may transfer your personally identifiable information to other countries outside of your home country, including to the United States (“U.S.”), by whatever means is determined to be appropriate in order to perform a background check that you authorized, or you were notified about. Your information may also be processed and stored in other countries where ClearStar’s service providers are located. Your information may be subject to U.S. or other laws for disclosure and may be accessible to foreign law enforcement, national security agencies, or courts. Note that the laws regarding personal information in some of the jurisdictions involved may be different or less stringent than the laws of the country in which you reside. Please be aware that ClearStar may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

ClearStar utilizes a variety of methods to transfer personal information across country borders. This can include consent, contractual methods, and/or regulatory authority certifications. ClearStar maintains appropriate contracts in place with service providers who may view your personal information. In the case of European Economic Area (“EEA”) and Swiss Personal Data, ClearStar abides by the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”) developed by the U.S. Department of Commerce.

CLEARSTAR’S EEA & SWITZERLAND PRIVACY STATEMENTS
ClearStar’s compliance with these Frameworks applies to personal information pertaining to an identified or identifiable individual that is received by ClearStar from the European Economic Area (“EEA”) or Switzerland, or other personal information that ClearStar acquires pursuant to its performance of services for its clients, agents, or other third-parties to which ClearStar has contractually agreed to apply this privacy policy. This Policy does not apply to data collected and used by ClearStar which is not EEA or Swiss related.

If you have questions regarding our EU-U.S. or Swiss-U.S. Privacy Shield Privacy Policy, contact:

Privacy@ClearStar.net
United States: (770) 416-1900 x872
United Kingdom (Toll Free): +44 (800) 3688795

EU-U.S. & Swiss-U.S. Privacy Shield Policy

ClearStar complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. ClearStar has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

The EU-U.S. and Swiss–U.S. Privacy Shield Policy applies to personal information ClearStar receives from the European Union and/or Switzerland.

ClearStar processes EU and Swiss Personal Data at the request of clients and other third-parties, and with the notification of or written consent of the data subject, for investigative, verification, employment and residential screening related purposes. This includes but is not limited to, identifying information about the data subject, employment and educational history, credit and insolvency reports, driving records, court records, criminal history checks, and other checks contracted by ClearStar’s client or by the data subject themselves. ClearStar uses this information to fulfill background screening requests by customers, which may be employers, other background screening companies, housing providers, and the data subject. ClearStar’s client is required to have obtained written consent from the data subject for this collection, unless such consent is prohibited in the jurisdiction. ClearStar maintains written agreements for services with its clients.

1. Notice

The scope of this Notice covers consumer report data that ClearStar has obtained on behalf of employers and other businesses by manually or electronically contacting the appropriate sources of the data (court records, references, licensing bureaus, etc.). ClearStar also performs services related to corporate litigation and investigative services as requested by ClearStar clients.

Information about how ClearStar collects and uses EU and Swiss Personal Data also follows below.

ClearStar gathers consumer and other data which it provides to employers or their agents (such as recruiters or staffing firms) for use in making employment-related decisions, such as who to hire, retain, promote, or re-assign. ClearStar also gathers consumer and other data which it provides to entities including landlords. Note that ClearStar does not engage in any of the decision-making activities for any data subjects. Below is an illustrative list of common ways in which employers use the data provided by this service:

  • Performance of applicant and employee background checks
  • Verification of the credentials of job applicants and current employees
  • Investigation into a suspicion of work-related misconduct or wrongdoing
  • Investigation into matters of employee compliance with employer policies, or
  • Investigation into matters of employee compliance with Federal, State, or local laws and regulations

ClearStar customers who are processing EU and Swiss Personal Data are contractually required to provide a legally compliant Notice to their data subjects, prior to submitting screening requests to ClearStar.

More information regarding the nature and scope of ClearStar’s data processing is available by contacting ClearStar in writing or by e-mail at the addresses listed on the Contact Us page or by writing to the contact listed below.

2. Choice

The information obtained by ClearStar is only used for the original purpose to which the data subject has consented, unless a new consent is obtained. A data subject may request ClearStar stop the processing of data they had previously consented to by contacting ClearStar directly. In such case, ClearStar will make every attempt to stop the processing as quickly as possible.

3. Accountability for Onward Transfer

ClearStar may engage agents to perform functions on our behalf, in order to provide services requested by customers or data subjects. ClearStar enters into service agreements with these agents and requires that the companies acting on ClearStar’s behalf abide by the ClearStar privacy policy and institute safeguards to protect the confidentiality of your information. In cases of onward transfer to agents of data of EU or Swiss individuals received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield, ClearStar is potentially liable.

ClearStar may disclose EU or Swiss Personal Data to clients, or their agents who enter into a written agreement with ClearStar, in which the client agrees to comply with the FCRA, if applicable. These ClearStar customers are contractually required to provide a legally compliant Notice to their data subjects prior to submitting screening requests to ClearStar.

4. Security

ClearStar takes reasonable procedures to protect EU and Swiss Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

5. Data Integrity and Purpose Limitation

The information obtained by ClearStar is only used for the original purpose to which the data subject has consented or the legal grounds for processing allow this access, unless a new consent is obtained or another legal ground for processing has been met. ClearStar processes EU and Swiss Personal Data in ways that are compatible with the purposes for which it has been collected (as identified in the Notice section above) or subsequently authorized by the individual. To the extent necessary for those purposes, ClearStar takes reasonable steps to ensure that EU and Swiss Personal Data collected are comprehensive, complete, current, and reliable for their intended use.

6. Access
A data subject, whose information is or was processed by ClearStar under the Privacy Shield, has the right to access all personal data collected and maintained about him or her by contacting us directly at Privacy@ClearStar.net. ClearStar affords the data subject a reasonable opportunity to correct, amend, or delete information that is incomprehensive or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated. In cases where the information is subject to the Fair Credit Reporting Act (“FCRA”), ClearStar complies with the FCRA’s requirements regarding access and correction rights of data subject.

ClearStar reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting their personal data. This is done to ensure the information is provided only to the subject of the data. If we are unable to provide the individual with access to his or her EU or Swiss Personal Data or to correct the data, we will notify the individual. To request information relating to his or her personal data, or to request processing be halted, a data subject may contact ClearStar at:

Privacy@ClearStar.net
United States: (770) 416-1900 x872
United Kingdom (Toll Free): +44 (800) 3688795

7. Recourse, Enforcement, and Liability

ClearStar is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In compliance with the U.S.-E.U. and Swiss-U.S. Privacy Shield Principles, ClearStar commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact ClearStar at:

Privacy@ClearStar.net
United States: (770) 416-1900 x872
United Kingdom (Toll Free): +44 (800) 3688795

ClearStar has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. ClearStar will cooperate with the EU Data Protection Authorities and the Swiss Federal Data Protection and Information Commissioner and will comply with the advice of such authorities with respect to Human Resources data transferred from the European Economic Area and Switzerland in context of the employment relationship.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Additional GDPR Information

ClearStar is a controller for the following activities:

  • ClearStar’s Website, www.clearstar.net
  • ClearStar’s customer management and accounting functions

Our lawful basis for processing will vary depending upon the purpose we are processing the information.

PurposeBasis for Processing
Respond to request for information6(1)(b) Performance of a Contract or Agreement or 6(1)(f) Legitimate Interests
Facilitate attendance at an event or webinar6(1)(a) Consent
Maintain records of prospective, current, or past customers6(1)(f) Legitimate Interests or 6(1)(b) Performance of a Contract or Agreement
Send newsletters6(1)(a) Consent
Manage Website performance and effectiveness6(1)(f) Legitimate Interests
Provide technology or services to customersDetermined by the customer

Your Rights under GDPR

In the European Economic Area, you have the right to access, correct or object to the information that ClearStar holds about you.

If we are processing your personal data on the basis of consent, you have the right to withdraw your consent at any time. Our newsletters contain an unsubscribe option to facilitate withdrawal.

You may have the right to request the erasure of your data from our systems. For example, if we are processing your personal data on the basis of consent and you have withdrawn your consent or if you have objected to our legitimate grounds for processing and your interests outweigh our interests.

To learn more about your specific rights, or to exercise your rights, please contact the ClearStar Privacy Office

Privacy@ClearStar.net
United States: (770) 416-1900 x872
United Kingdom (Toll Free): +44 (800) 3688795

ClearStar strives to address concerns lodged by data subjects about our handling of their personal information. If you are not satisfied with ClearStar’s response to your concerns, you have the right to lodge a complaint with the Information Commissioner’s Office.

Terminology Used in this Privacy Notice

Consumer: The individual who uses ClearStar services or is the subject of a service provided by ClearStar. Also known as a “data subject”.

Consumer Reports: This is a term is defined under the U.S. federal Fair Credit Reporting Act (“FCRA”). When providing Consumer Reports to its Clients, ClearStar acts as a Consumer Reporting Agency (“CRA”) as the term is defined under the FCRA. The report ClearStar provides to its client is the Consumer Report. This is the report on the background or drug screen requested by the ClearStar customer.

Controller: the person or entity who determines the purpose of the data processing.

CRA: A Consumer Reporting Agency as the term is defined under the FCRA, operating in accordance with the requirements of the FCRA. This is an entity that provides a Consumer Report. ClearStar is a CRA.

Data Subject: The individual whose data is being processed. This person may also be referred to as a “consumer”.

Personal Information: This is information that identifies or can identify an individual.

Processor: the person or entity who processes personal data on behalf of the controller.
Third Parties: Entities other than yourself or ClearStar. These are typically service providers to ClearStar but may also include government entities or direct sources of information such as schools or employers.